Section 14A and Rule 8D Disallowance Deep-Dive for FY 2025-26 Tax Audits Under Section 44AB and Section 536 Sub-Clause 4 of the Income-tax Act 2025: Exempt-Income Expense Allocation, Three-Limb Rule 8D(2) Computation, Form 3CD Clause 21(h), Maxopp Investment Satisfaction Doctrine, South Indian Bank Own-Funds Presumption, Strategic Foods Carve-Out, and the September 30, 2026 Practitioner Defence Playbook
Practitioner deep-dive on Section 14A and Rule 8D for FY 2025-26 tax audits, preserved by Section 536 sub-clause 4 of the Income-tax Act 2025. Three-limb Rule 8D(2) computation, Form 3CD Clause 21(h) disclosure, Maxopp Investment satisfaction-recording defence, South Indian Bank own-funds presumption, Strategic Foods carve-out for controlling stakes, Section 115JB MAT add-back, and Section 270A penalty grid for under-reporting.